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“faceless assessment”

Assessment ProceduresSection 144BSection 144B2,420 judgments

The decision most relied on for faceless assessment is Kankanala Ravindra Reddy v. ITO (156 Taxmann.com 178), cited in 213 judgments on BharatTax.

Leading authorities on faceless assessment

Kankanala Ravindra Reddy v. ITO
156 Taxmann.com 178 · 2023 · High Court
213
citing judgments

A notice issued under section 148 of the Income Tax Act is invalid if the Income Tax Department fails to follow the prescribed procedures, including obtaining the necessary approvals under section 151 or adhering to the faceless assessment scheme mandates under section 151A.

Jatinder Singh Bhangu v. Union of India
165 Taxmann.com 115 · 2024 · High Court
106
citing judgments

The faceless assessment scheme under Section 151A applies from the stage of issuing show cause notices under Sections 148 and 148A, and non-compliance with the scheme or related notifications vitiates the subsequent assessment proceedings. Assessment proceedings are considered to commence upon the issuance of such a show cause notice.

Ram Narayan Sah v. Union of India
163 Taxmann.com 478 · 2024 · High Court
97
citing judgments

A notice under section 148 of the Income-tax Act, 1961, cannot be issued by the Jurisdictional Assessing Officer after the introduction of faceless assessment under Section 151A read with Section 144B. Such a notice is invalid as it defeats the object of faceless assessment and is not in consonance with CBDT notifications.

T.K.S. Builders (P) Ltd. v. ITO
469 ITR 657 · 2024 · High Court
88
citing judgments

Section 144B of the Income Tax Act does not completely divest the Jurisdictional Assessing Officer (JAO) of their power to assess or reassess, even with the introduction of the Faceless Reassessment Scheme.

Triton Overseas (P) Ltd. v. Union of India
156 Taxmann.com 318 · 2023 · High Court
55
citing judgments

A notice under Section 148 for income escaping assessment issued by the Jurisdictional Assessing Officer is invalid if it does not comply with Section 151A and relevant CBDT notifications concerning faceless assessment.

Pvt. Ltd. v. DCIT
466 ITR 474 · 2024 · High Court
53
citing judgments

Reassessment notices under Section 148A, issued in the context of faceless assessment proceedings, must be issued by the designated Faceless Assessing Officer and not by a Jurisdictional Assessing Officer.

Mark Studio India (P.) Ltd. v. Income-tax Officer, High Court of Madras
169 Taxmann.com 542 · 2024 · High Court
50
citing judgments

The National Faceless Assessment Centre (NaFAC) does not have the power to issue notices under Section 148 or 148A of the Income Tax Act. Its jurisdiction for assessment or reassessment begins only from the stage of issuing notices under Section 142(1) or 143(2).

Samp Furniture (P) Ltd. v. ITO
165 Taxmann.com 581 · 2024 · High Court
50
citing judgments

The issuance of a notice under section 148A, including the order under section 148A(d), is a mandatory procedural step before reassessment proceedings can be initiated under section 147/148. Failure to comply with this requirement renders the subsequent reassessment proceedings invalid.

Judgments citing faceless assessment

Schineler India Pvt Ltd, Mumbai vs. Dcitrg 15(3) (2), Mumbai

In the result, ground no. 6 raised by the assessee is allowed

ITA 724/MUM/2022[2017-18]Status: DisposedITAT Mumbai31 Dec 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2017-18 Schindler India Pvt Ltd Dcit Schindler House, Main Street, Range 15(3) (2) Hiranandani Gardens, Powai, Vs. Mumbai Mumbai - 400076 (Pan: Aaecs1548J) (Appellant) (Respondent) Present For: Assessee : Ms. Chandani Shah, Ms. Niddhi Agarwal & Ms. Riddhi Maru, Cas Revenue : Shri Ajay Chandra, Cit Dr Date Of Hearing : 08.10.2025 Date Of Pronouncement : 31.12.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Final Assessment Order Passed By National Faceless Assessment Centre, Delhi (Nfac) Vide Order No. Itba/Ast/S/143(3)/2021-22/1040015716(1) Dated 22.02.2022 U/S. 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”) Pursuant To The Directions Of Ld. Dispute Resolution Panel-2, Mumbai, (Drp) Vide Order No. Itba/Drp/F/144C(5)/2021-22/1039079646(1), Dated 25.01.2022, Passed U/S. 144C(5), For Assessment Year 2017-18. 2. Grounds Taken By Assessee Are Reproduced As Under: “Ground I. Legal Grounds

For Appellant: Ms. Chandani Shah, Ms. Niddhi Agarwal and Ms. Riddhi Maru, CAsFor Respondent: Shri Ajay Chandra, CIT DR
Section 143(3)Section 144C(5)Section 92CSection 92C(3)

GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal filed by the assessee is against the final assessment order passed by National Faceless Assessment Centre, Delhi (NFAC) vide order no. ITBA/AST/S/143(3)/2021-22/1040015716(1) dated 22.02.2022 u/s. 143(3) r.w.s. 144C(13) of the Income-tax Act, 1961 (hereinafter referred

Income Tax Officer, Rohtak vs. Pankaj Jain, Rohtak

In the result, the appeal filed by the Revenue is dismissed

ITA 2295/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Dec 2025AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmaincome Tax Officer, Vs. Pankaj Jain, Rohtak. 123/34, Vishwakarma Kathmandi, Rohtak – 124 001 (Haryana). (Pan : Azupj6345A) (Appellant) (Respondent) Assessee By : Shri Shri Naveen Gupta, Advocate Shri Nakul Gupta, Advocate Revenue By : Shri Ajay Kumar Arora,Sr. Dr Date Of Hearing : 06.11.2025 Date Of Order : 30.12.2025 Order Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 04.02.2025 For The Assessment Year 2018-19 Raising Following Grounds Of Appeal :- “1. The Learned Cit(A) Has Erred In Law & On Facts In Not Upholding The Validity Of The Notice Issued Under Section 148 Of The Income Tax Act, 1961 (The Act) Without The Proper & Mandatory Compliance With The Provisions Of Section 148A(B). 2. The Learned Cit(A) Has Further Erred In Law & On Facts By Failing To Consider That The Then Ao Has Given Notice U/S 148A(B) To Assessee On 31.03.2022

For Appellant: Shri Shri Naveen Gupta, AdvocateFor Respondent: Shri Ajay Kumar Arora,Sr. DR
Section 133(6)Section 142(1)Section 143Section 147Section 148Section 148ASection 151Section 151ASection 292BSection 37(1)

provisions of Section 151A, notice could not be issued by the Jurisdictional Assessing Officer and should have been issued by the Faceless Assessing Officer. In view of these circumstances, the proceedings initiated against the assessee is suffered from severe legal lapses and is liable to be quashed. In this regard ... observed that the JAO and FAO have committed irreparable mistakes in 8 this assessment order and such mindless reassessment order passed by the Faceless Assessment Unit and casual approach of the JAO is not at all maintainable before the eyes of law. 7. Ld. CIT (A), after recording the above

Catholic Education Society, Mumbai vs. Income Tax (Exemption), Mumbai

In the result, appeal of the assessee is allowed

ITA 5030/MUM/2025[2020-21]Status: DisposedITAT Mumbai29 Dec 2025AY 2020-21

Bench: Shri Sandeep Gosain & Shri Girish Agrawalcatholic Education Society Vs Income Tax Department Cit 338, Bb, Michael Villa, New (Exemption) Hall Road, Kurla (W), Mumbai Room No.601, 6Th Floor, 400070 Cumballa Hill Mtnl Te Building, Pedder Road, Dr. Gopalrao Deshmukh Marg, Pan: (Aaatc5704H) Mumbai 400026 Appellant Respondent Present For: Appellant By : Dr K Shivram Sr. Advocate & Shri Shashi Bekal, Ca Respondent By : Shri R.A. Dhyani, Cit Dr Date Of Hearing : 01.10.2025 Date Of Pronouncement : 29.12.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Cit(Exemptions), Mumbai Vide Order No. Itba/Rev/F/Rev5/2024- 25/1075306167(1) Dated 30.03.2025 Passed Against Assessment Order U/S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 05.09.2022 For Ay 2020-21. 2. Grounds Taken By The Assessee Are Reproduced As Under: “1. On Facts & Circumstances Of The Case & In Law, The Ld. Commissioner Of Income-Tax (Exemption) (Cit(E)) Has Erred In Issuing A Notice & Passing An 2

For Appellant: Dr K Shivram Sr. Advocate and Shri Shashi Bekal, CAFor Respondent: Shri R.A. Dhyani, CIT DR
Section 11Section 12ASection 13Section 13(3)Section 142(1)Section 143(1)Section 143(3)Section 263

strength of nearly 8296 students enrolled in various institutions maintained by the assessee. Case of the assessee was selected for limited scrutiny under faceless assessment scheme as per CASS System to verify the following two issues: 3 ITA No. 5030/Mum/2025 AY 2020-21 Catholic Education Society a. Ratio of expenditure